GDPR Privacy Statement

1. Who does this GDPR privacy statement apply to?

1.1          Chateau de Steinbach (“Chateau de Steinbach”, “the Company” or “We”).

This GDPR Privacy Statement applies to the processing of personal data by the company established in the European Union, regardless of whether the processing takes place in the Union or not;

1.2          We are committed to protect your privacy and to process your personal data in an open and transparent manner, in particular with respect of the General Data Protection Regulation 2016/679 of 27 April 2016 (“GDPR”).


2. What is covered by this GDPR Privacy STATEMENT?

2.1          With this GDPR Privacy Statement we would like to inform you about why and how we process your personal data when we perform our business activities or when you use our website and any of the services we offer through our website, who we give that information to, what your rights are and who you can contact for more information or queries.

2.2       Our website may link to other sites provided by other affiliated companies/entities or by third parties. Whilst we try to link only to websites that share our high standards and respect for privacy, we are not responsible for the content or the privacy practices of other websites. When linking to any such sites, we strongly recommend you to review the GDPR Privacy Statements on these sites, before disclosing any personal information.


3. Why we use your data

We only process your personal data for legitimate business reasons. These purposes include, but are not limited to:

  • dealing with enquiries and requests (e.g. sent via the online “contact us” form);
  • gathering statistics about the use of the website;
  • improving the website’s performance and design.
  • the provision of information on our company, services and activities;
  • marketing and sales;
  • public relations and press contacts;
  • statistics and market research;
  • respecting our legal obligations;
  • security

4. The legal grounds for processing your data

When you send a message via the online “contact us” form, your personal data will in principle be processed for the purposes of our legitimate interests (namely the interest to handle all enquiries, requests sent via this form in the best possible way).

Before relying on legitimate interests, we will always determine case by case whether our interests are not overridden by your interests, fundamental rights and freedoms.

We process your personal data for the purposes mentioned above for the purposes of the legitimate interests of the Company and/or of a third party, including (but not limited to) our business activities. In this respect, we will always determine case by case whether our interests are not overridden by your interests, fundamental rights and freedoms.

If we have the legal obligation to obtain your free, informed, specific and unambiguous consent to process your personal data for certain purposes (e.g. specific direct marketing or market research activities), we will only process your data for such purposes to the extent that we have obtained such consent from you.

  • when necessary for the performance of contracts to which you are party or in order to take steps at your request prior to entering into a contract;
  • when necessary for compliance with our legal obligations;
  • for the purposes of the legitimate interests of the Company and/or of a third party, including (but not limited to) our business activities, customer and supplier management, etc. In this respect, we will always determine case by case whether our interests are not overridden by your interests, fundamental rights and freedoms.


5.            Your Rights

5.1          You have several rights concerning the information we hold about you. We would like to inform you that you have the right to:

  • obtain confirmation that we are processing your personal data and request a copy of the personal data we hold about you;
  • ask that we update the personal data we hold about you, or correct such personal data that you think is incorrect or incomplete;
  • ask that we delete personal data that we hold about you, or restrict the way in which we use such personal data if you believe that there is no (longer a) lawful ground for us to process it;
  • withdraw consent to our processing of your personal data (to the extent such processing is based on consent);
  • receive a copy of the personal data concerning you, which you have provided to us, in a structured, commonly used and machine-readable format and to transmit such personal data to another party (to the extent the processing is based on consent or a contract);
  • object to our processing of your personal data for which we use legitimate interest as a legal basis, in which case we will cease the processing unless we have compelling legitimate grounds for the processing.

You have also the right to object at any time to the processing of personal data for direct marketing. If you do not want to continue receiving any direct marketing from us, you can contact us (see below) or click on the unsubscribe function in any such communication. In that event, the personal data shall no longer be processed for such purposes.

5.2          In order to exercise any of your rights, you can send us a request, indicating the right you wish to exercise by e-mailing us at

You may also use these contact details if you wish to make a complaint to us relating to your privacy.

5.3          If you are unhappy with the way we have handled your personal data or any privacy query or request that you have raised with us, you have a right to complain to the Data Protection Authority (“DPA”) in your jurisdiction. If you would like to be directed to the appropriate DPA, please contact us.


6. How we obtain DATA

We may obtain your personal data when you use the website and its services. This may be for instance the case when you fill in the “contact us” form on the website, etc.

We may obtain you personal data in the framework of the execution of our business activities.

We may obtain such personal data because you give them to us (e.g. by contacting us, by completing online forms, …), because others give them to us (e.g. your employer or third party service providers that we use in the framework of our business activities) or because they are publicly available.

When we obtain personal data from external parties, we make reasonable efforts to enter into contractual clauses with these parties obliging them to respect the data protection legislation. This can be done by obliging this party to provide you with all necessary information or – if necessary – to obtain your consent for processing the personal data as described in this GDPR Privacy Statement.


7.            Data we collect

On our website, you have the possibility to contact us by completing the “contact us” form. The following data are collected through this form:

  • first and last name
  • e-mail address;
  • phone number and
  • your message.


8.            Disclosures

8.1          We may disclose your personal data to affiliated companies, third parties that provide services to us that reasonably require access to personal data relating to you for one or more of the purposes outlined in the “Why we use your data” section above. The following external parties may for instance be involved:

  • external service providers we rely on for various business services;
  • law enforcement authorities in accordance with the relevant legislation
  • external professional advisors (e.g. attorneys or consultants of the company).

If our business enters into a joint venture with or is sold to or merged with another business entity, your information may be disclosed to our new business partners or owners.

8.2          Please note that some of the recipients of your personal data referenced above may be based in countries outside of the European Economic Area whose laws may not provide the same level of data protection. To ensure that your personal data are processed in accordance with the principles related to data protection, SA Chateau de Steinbach Holding has adopted appropriate safeguards in line with the GDPR. If you want to obtain more information about the appropriate safeguards in place, you can e-mail us at

8.3          In general, we will take all steps reasonably necessary to ensure that your data is treated securely and in accordance with this GDPR Privacy Statement.

We reserve the right to disclose your personal information as required by law, or when we believe that disclosure is necessary to protect our rights and/or comply with a judicial proceeding, court order, request from a regulator or any other legal process served on us.


9.            Security of your data

9.1          We employ strict technical and organizational (security) measures to protect your information from access by unauthorized persons and against unlawful processing, accidental loss, destruction and damage both online and offline.

These measures include:

  • training to relevant staff to ensure they are aware of our privacy obligations when handling personal data;
  • administrative and technical controls to restrict access to personal data on a ‘need to know’ basis (passwords, digital certificates);
  • technological security measures, including fire walls, encryption and anti-virus software;
  • physical security measures, such as staff security badges to access our premises.

9.2          Although we use appropriate security measures once we have received your personal data, the transmission of data – especially over the internet (including by e-mail) – is never completely secure. We endeavor to protect personal data, but we cannot guarantee the security of data transmitted to us or by us.

We limit access to your personal information to those who we believe reasonably need to come into contact with that information in order to carry out their jobs.


10.         Data retention

10.1.1    Your personal data will not be retained longer than necessary for the purposes described above.

10.1.2    As a general rule, personal data obtained through the contact form on our website are stored for a period of 5 years from the last contact with you.

10.1.3    As a general rule, records in the framework of our business activities that may contain personal data (e.g. contracts, orders, correspondance etc.) are stored for a period of 10 years.

10.1.4    Personal data processed for direct marketing purposes, are however stored for a period of 3 years as from the last contact with the individual concerned. If you have become a customer during this period, we may however retain your personal data for a longer period, namely 10 years as from the delivery of the products or services, or as from the latest contact with AR Metallizing (if this contact would take place at a later date).

10.1.5    Depending on the specific situation and the applicable national legislation, we may however retain your personal data for a longer period. This will in particular be the case if any of the following periods is longer : (i) as long as is necessary for our daily business; (ii) any retention period that is required by law; or (iii) the end of the period in which litigation or investigations might arise.


11. Automated Decision-making

11.1       Automated decisions are defined as decisions about individuals that are based solely on the automated processing of data and that produce legal effects that significantly affect the individuals involved.

11.2       As a rule, your personal data will not be used for automated decision-making. We do not base any decisions about you solely on automated processing of your personal data.


12.  How to contact us?

We hope that this GDPR Privacy Statement helps you understand, and feel more confident about, the way we process your data. If you have any further queries about this GDPR Privacy Statement and this website in general, please contact us by e-mailing us at


13.  Changes to this GDPR Privacy Statement

We may modify or amend this GDPR Privacy Statement from time to time. Any changes we may make to this GDPR Privacy Statement in the future will be posted on this page. To let you know when we make changes to this GDPR Privacy Statement, we will amend the revision date at the top of this page. The new modified or amended GDPR Privacy Statement will apply from that revision date. Please check back periodically to see changes and additions.


Last date of revision: 28 May 2018